We are committed to protecting your privacy. For any personal data we collect or you submit to us, this Privacy Policy (“Policy”) explains why we collect the data, what we do with the data, and your rights and choices when it comes to your personal data.

When you use our services (“Services”) by accessing our website at https://smartframe.io/ (the “Website”), interact with images that use our SmartFrame Technology (“SmartFrame Images”), browse websites that contain SmartFrame Images, communicate with us via our online, telephone or social media channels, or submit your data anywhere this Policy is posted, this Policy will apply to you. 

So we can remain transparent about how we use your personal data, when there are significant updates to the Policy we will notify you if we have a means of contacting you, but you are invited to continually revisit the policy to check for updates.

This Policy was last updated on 31 October 2020.

References to (“we”, “our”, or “us”) are to SmartFrame Technologies Limited, a company registered in England and Wales. We are the Data Controller and determine the purpose and manner in which your personal data is used.

Our Website, SmartFrame Images or the websites hosting our SmartFrame Images may contain links to other websites operated by other organizations. These third-party organizations will have their own privacy policies that you should read carefully before providing any of your personal data as we do not accept any responsibility or liability for the websites of other organizations.

Upon subscribing to our Services and later accessing your account, you may provide us with:

• Your personal details, including your name, title, postal and billing addresses, email addresses, phone numbers and date of birth
• Your debit or credit card details, bank details and other payment information
• Your account login details, such as your username and password

When you browse our Website or a website with a SmartFrame Image, or interact with our SmartFrame Images, we may collect:

• Purchase Information (e.g. the plan you have subscribed to, when and where you bought it and how you paid for it)
• Information about your online browsing behavior on our Website, information about your interactions with our SmartFrame Images, and information about your activities when you click on an advertisement that we display with one of our SmartFrame Images – this information will let us know such things as the amount of time you spend browsing our Website or engaging with our SmartFrame Images and whether you have viewed one of our adverts
• Information (including the make, model and operating system, IP address and browser type) about any devices you have used to access our Services or interact with our SmartFrame Images

When you obtain a SmartFrame Image from one of our partners, we may collect:

• Your email address 

When we communicate with each other or you sign up for our newsletters or take part in our surveys about our Services, we may collect:

• Personal data you provide about yourself anytime you contact us about our Services, (for example, your name, username and contact details) including by phone, email or post or when you speak with us through social media
• Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
• Your responses to customer surveys and questionnaires

We cannot guarantee the security of any personal data that you transfer over the internet to us; however, we do take appropriate technical and organizational measures to safeguard your personal data. We use technical safeguards such as firewalls and data encryption, and we employ access controls to our buildings and files to keep your data safe.

• We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
• We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We will ask for proof of identity before we share your personal data with you. 
• We will reveal only the last four digits of your credit card number when confirming an order.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. If we do this we ensure that your privacy rights are respected in line with this Policy. The most common way we do this is to put in place a specific type of contract. A copy of this type of contract can be found here

We set out below how we use your data and the lawful basis for doing so. References to our “legitimate interests” are to those interests we have in running our business, developing our products and services, delivering and improving our products and services, and ensuring an excellent customer experience in a way that may reasonably be expected and doesn’t infringe on your rights and freedoms.